Reid v. State, 319 Ga. App. 782

Reid appeals his conviction for child molestation and sexual battery, challenging insufficiency of the evidence and the trial court's handling of a jury note.
Victim, age 10–11, testified about multiple incidents in 2004–2005 at two Floyd County houses where Reid shared a bed and molested her.
The acts included pulling down pants, touching genitals, and touching with his penis; victim testified the molestations occurred about five times.
After the incidents, the victim disclosed to her mother and school counselor, and later recounted them in a DFCS interview.
Reid was charged with four counts of child molestation and two counts of sexual battery; the State’s witnesses included the victim’s mother and school counselor, who corroborated the outcry.
During deliberations, the jury asked about Reid’s response to the arresting officer; the trial court issued a written response without informing Reid or his counsel; Reid was found guilty on two counts of child molestation and both sexual battery counts and sentenced to 20 years with 5 to serve; post-trial motions were denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient to convict without corroboration?	Reid argues no corroboration for the victim’s testimony.	State contends a single witness can prove the crime and corroboration existed via mother and counselor.	Yes; evidence sufficient; single witness suffices and corroboration existed.
Did the trial court’s external communication with the jury without Reid or counsel violate his right to counsel?	Reid contends error from court communicating with jury outside presence of defendant and counsel.	Court’s communication was improper but discretionary; no abuse shown and rehearing of testimony not required.	Harmless error; communication occurred but no demonstrated prejudice or harm.

Reese v. State, 270 Ga. App. 522, 523 (2004) (Ga. App. 2004) (evidence viewed in light most favorable to the prosecution; no weigh or credibility assessment by appellate court)
Jackson v. Virginia, 443 U.S. 307, 319 (1979) (U.S. 1979) (requires a rational trier of fact to find essential elements beyond a reasonable doubt)
Burtts v. State, 269 Ga. 402, 403 (1998) (Ga. 1998) (trial court cannot communicate with jury outside defendant and counsel; potential prejudice presumed)
Lowery v. State, 282 Ga. 68, 75 (2007) (Ga. 2007) (failure to inform counsel about jury note violates right to counsel; harm analysis required)
Brown v. State, 237 Ga. App. 231, 234-235 (1999) (Ga. App. 1999) (harm from failure to inform counsel on jury note evaluated under Burtts framework)
Scales v. State, 171 Ga. App. 924-925 (1984) (Ga. App. 1984) (acknowledges lack of corroboration requirements for child molestation testimony; corroboration not required in this context)
Cantrell v. State, 231 Ga. App. 629, 630 (1998) (Ga. App. 1998) (Georgia law does not require corroboration of a child molestation victim's testimony)